If you are a client of Monnos’ services or just visiting our website, this Policy applies to you. Please, read this carefully. Monnos aims to simplify the use of Crypto by bringing usability to it, blending Exchange and Wallet functionality into a one solution at your mobile.
1. Our Responsibilities
We act as a “Data Controller” (for GDPR) or as a “Controlador” (for LGPD) of your personal data, if you are a client or a visitor to our website. This means that we determine how and for what purpose your data will be processed. We are registered as a Data Controller before the Federal Data Protection and Information Commissioner (FDPIC).
2. Your responsibilities
Monnos is a business service directed to and intended for use only by those who are 18 years of age or over. We do not aim at children, and we do not knowingly collect any personal data from any person under 18 years of age.
4. Location of the services offered
4.1. If you are a client or a visitor located in Europe, this policy applies, as well as the specific sections regarding the European legislation, i.e., the General Data Protection Regulation (GDPR).
4.2. If you are a client or a visitor located in Brazil, this policy applies, as well as the specific sections regarding the Brazilian Data Protection Legislation (Lei Geral de Proteção de Dados – LGPD).
5. How and when we collect your data
We might collect data directly from you, especially if you are a client and agreed with the contract between us for the purposes of the services you agreed with us to be provided at our APP. We may also collect information automatically, in case you browse our website or when we send an e-mail to you.
5.1. For the services we provide to you, in case you choose to enroll to our website and our services, we will collect your data to execute the contract between us and to create your registry, and also comply with anti-money laundering and similar legislation.
6. Types of data we collect
we collect and/or receive from you your contact information, financial information, and other data, as follows.
a. Contact information: The information that we collect depends of how big is the amount of crypto or Fiat money that you will use at our platform, but it will include at least your name, date of birth, address, e-mail, telephone number, identity’s number, declaration of being or not a Politically Exposed Person.
b. Financial information: Your bank account number. The credit card details will be checked by our partner, we will never store it. We might also request other information in accordance with our PLD program. We might also ask for further information, for security purposes, so as to prevent fraud and for risk of the credit assessment.
c. Other data we collect or receive from you: Login information, IP address, geolocation information, time zone setting, operating system, and version, type of browser and version, browser plug-in types. We also collect on how you use our website, such as the pages you visit and the paths you take, what do you do in each page, how long you stay in each page, services viewed, and other actions.
7. Sensitive data
We do not collect sensitive data from you. For Europe and the GDPR, sensitive data means racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offenses or alleged offenses.
8. How we use your data and for what purpose
a. Providing our services: Processing your data to provide the services you are agreeing with us and at your request. Legal basis: Contract.
b. Your Registry (KYC – know your client – procedure): Collecting and processing your data is necessary to comply with our Compliance and KYC procedure. Your data may be shared with the appropriate authorities to comply with anti-money laundering and similar legislations. Legal basis: Legitimate Interest (Fraud Prevention – GDPR) / Legal Obligation / Credit Protection (LGPD).
c. Assisting you (Customer Support): Solving issues by e-mail, phone or chat, interacting with you to notice any changes to our services or any bug fixing. Legal basis: Contract.
d. Marketing: E-mails and messages sent to you with content related to your services and also about new services, products or features. Legal basis: “Legitimate Interest” (Legítimo Interesse). 3
e. Improving our website and services: Testing features, traffic optimization, managing pages of our website, heat map of our website, data analysis, and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this. Legal basis: Contract
9. Legal basis
Besides the specific purpose, we must have also a legal basis to collect and process your data. Thus, you can find below the hypothesis under which processing your data for the purposes we are informing you is legal.
a. Contract: When processing your data is necessary for a contract you have with us, or because we have asked you specific information to complete your registry with us before agreeing with the contract.
b. Legal Obligation: Processing your data is necessary because a law or regulation demands we do so.
d. Legitimate Interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, but only if we balance them with your rights and interest. It includes the actions we listed above in Improving our website, services, and Marketing and also fraud prevention and the security of our services.
You can exercise your rights by sending us an email at email@example.com or by accessing your registry in our APP.
11.1. You have the right to confirm we have data about you, to access and be informed about what information (if any) we have about you, and you can also ask us more information about: a. The purposes of the processing of your data. b. The categories of data being processed. c. Third parties to whom the data may be shared or transferred. d. How long your data will be stored (or the basis we used to determine how long we will store it). e. The other rights you may have including those listed in this section.
11.2 You also have the following rights: a. Right to update or correct your information within us, accessing your registry page in our website to change, updating or correcting any information. If you are not able to do so, please contact us by e-mail (firstname.lastname@example.org) b. Right to oppose to the use of your data for direct marketing, by opting-out on your registry page in our application (“APP”). c. Right to have a copy of your data in so that you can provide it to another service (portability). d. Right to delete your data (right to be forgotten), asking us to erase any personal data we hold about you. Your information can be deleted if we do not have to maintain such information for the purposes of the services you have with us (e.g. we might have to keep your data to comply with specific legislation). Please contact us by e-mail (email@example.com) 5 e. Right to file a complaint. We kindly ask that you contact us in order to handle any problems you might have. If we fail to address your concern, you can file a complaint to the Federal Data Protection and Information Commissioner (FDPIC), either by e-mail or calling them on Tel. +41 (0)58 462 43 95 (from Monday to Friday from 10am to 12pm) or as directed on their website at https://www.edoeb.admin.ch/edoeb/en/home/thefdpic/contact.html.
11.3 We will provide you with the information of your request as soon as we can, respecting the 30 days term for persons located inside European territory as provided for under the European legislation. We will let you know the reasons in case we cannot respond to your request.
11.4 We may inform you that additional time is necessary, in case the request is complex. It may also take more time to completely respond to you if that could significantly impact the rights and freedoms of other people.
12. Where do we store and process your data
12.1 Your data is also processed by third parties in the data processing facilities identified below (Third Parties We Work With).
JUMIO (Palo Alto – EUA) – Responsible of the flow of the Onboarding Digital;
AWS (Amazon Web Services) – Responsible for our cloud.
13. How long do we store your data
Also, we will delete your personal data from our files after 5 years from the last time you used our services or as agreed with you in the service contract. We will also delete your data if you request us to do so, as described above and unless no other reason exists.
14. How secure is the data we collect
We have physical and electronic procedures to safeguard and keep the information we collect safe, and that includes internal politics. Also, you are responsible for securely keeping your login, password and other information needed to access this website. In case you have reason to believe that your data has been exposed, please contact us by e-mail, on firstname.lastname@example.org
15. Third Parties We Work With
Like any other digital service provider, we use other companies to assist us with specific tasks, such as hosting the website, marketing, storing information, sending e-mails, etc. By using them, we might share some of your data to perform specific tasks, for the purposes we described above (How we use your data and for what purpose). That means that we only share the information that is necessary for them to do their job and for the tasks, we ask them to do, following the policies of Monnos. 6
15.1 In the case of third parties located outside the EEA (or Brazil, as applicable), we use the same security level, as explained above (Where do we store and process your data). In case the company we share is located in the United States of America (USA), we make our reasonable efforts to ensure that the organization in question has a current certification with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks administered by the U.S. Department of Commerce’s International Trade Administration (ITA).
Cookies are used to collect information about how you use and interact with a website. There are two types of cookies. The session cookies, that last during the session and self delete when you leave the webpage. The persistent cookies do not delete themselves but help a website recognize you when you come back, to improve your experience.
TERMS AND CONDITIONS OF USE OF THE MONNOS PLATFORM
Last Update April 20, 2020
READ WITH ATTENTION
THE MONNOS PLATFORM IS NOT A DISTRIBUTOR OF SECURITIES. THEREFORE, NO TOKEN MIRRORED IN THE PLATFORM REPRESENTS EQUITY, COLLECTIVE INVESTMENT CONTRACTS, TRANSFERABLE SECURITY OR ANY OTHER TYPE OF ASSETS CONSIDERED SECURITIES.
ALL STRATEGIES FOR EXCHANGING CRYPTOGRAPHED ASSETS ARE THE SOLE AND EXCLUSIVE RESPONSIBILITY OF THE USER. YOU SHOULD NOT START EXCHANGES IF YOU DO NOT UNDERSTAND THE RISKS INVOLVING THE NATURE OF THESE TRANSACTIONS.
THE PRODUCTS AND SERVICES OF OUR PLATFORM ARE NOT OFFERED FOR USE IN THE UNITED STATES OF AMERICA, ITS TERRITORIES OR POSSESSIONS, INCLUDING ANY PERSON IN THE UNITED STATES OF AMERICA, CITIZENS OF THE UNITED STATES OF AMERICA, PERMANENT RESIDENTS OF THE AMERICAS, GREEN CARDS HOLDERS) AND COMPANIES ESTABLISHED IN ACCORDANCE WITH THE LAWS OF THE UNITED STATES OF AMERICA OR ANY PERSON RECOGNIZED AS ‘US PERSON’ UNDER RULE 902 (K) (1) REGULATION ‘S’, OF THE UNITED STATES OF AMERICA.
ADDITIONALLY, THE AVAILABLE PRODUCTS AND SERVICES ARE NOT OFFERED FOR USE IN ANY COUNTRY OR JURISDICTION OR FOR ANY PERSON IN WHICH THE USE OF THE SERVICES OFFERED BY MONNOS CONSTITUTES A VIOLATION OF THE LAW OR NEEDS A SPECIAL AUTHORIZATION AUTHORIZATION THAT DOES NOT DISCLAIM.
THE PRODUCTS AND SERVICES OFFERED BY MONNOS ARE ONLY AVAILABLE FOR THOSE WHO HAVE THE DUE CAPACITY, POWERS OR LICENSES TO ENJOY THEIR FUNCTIONS, WHEN YOU REGISTER WITH MONNOS YOU DECLARE ALL YOUR LEGAL REQUIREMENTS FOR YOUR LEGAL REQUIREMENTS. ENJOYING A LEGAL AND UNMISSED WAY OF MONNOS ‘SERVICES AND PRODUCTS.
These Terms and Conditions of Use (“Term” or “Terms”) govern access and use by Users (“User” or “You”) of the Monnos Platform. The Platform is maintained by the company Kryeg Solucoes Digitais EIRELI (trade name: MONNOS), a company created under the laws of Brazil, registered with the CNPJ under number 31.238.023 / 0001-62 (“Monnos”, “our” or “our”) ).
1.1 By use, it means access to the Monnos Platform through the website https://monnos.com and https://monnos.com.br, as well as through the applications (“Apps”) for Monnos iOS or Android phones (together, “Platform”), effected through registration in the respective virtual environments.
1.2 Monnos offers its Users an intermediation platform for crypto purchase and sale operations. Through the Platform, the User has access to competitive prices in the global market, being integrated to several exchanges, through the Exchange Hub system. Also on the Monnos Platform it is possible to access other features, described in item 7.
1.2.1 Monnos neither buys nor sells crypto, allowing on its Platform the approximation between Users, who can sell and buy digital assets, according to their preferences. In addition, other features described in item 7 are offered.
1.3 Monnos does not offer its services in jurisdictions where such distribution, publication or use would be contrary to the law or regulatory provisions, or even where Monnos does not have the necessary registration or license necessary to operate. Individuals or legal entities subject to these prohibitions, whether due to their nationality, their place of residence or for other reasons, should not access or use the Platform.
By agreeing to these Terms, the User confirms that he is over the age of 18 or has the age of majority under the laws of his State of residence and / or nationality, having full civil capacity to be a party and adhere to these Terms.
The Terms may, at any time, be changed by Monnos, due to (i) legislative updates, (ii) in services, (iii) in technology, (iv) in Monnos’ internal policy, by (v) change in the framework of the Monnos economic group or as a result of other corporate issues that imply modification of the subject service providers or holders of intellectual property necessary for the provision of Monnos services, as well as in the face of any other issues that affect the legal relationship between Monnos and its Users. The Terms may also be modified at Monnos’ convenience at any time. The User will be notified of updates within the Platform. If the Platform continues to be used after the date of modification, amendments to the Terms are deemed accepted. If the User does not agree with the changes made to these Terms, he must stop using the Monnos Platform immediately.
6. Money Laundering Prevention and Terrorism Financing Policy
Monnos Users must complete a form according to the value of their transactions and the source of their funds, committing themselves to answer questions for the Monnos team whenever requested.
6.1. The User undertakes to provide true, current and complete information and undertakes to always keep it updated.
6.2. Monnos is not responsable for the information provided by each User, such information being provided under the User’s sole responsability.
6.3. The provision of false information or the misuse of third party data in your own name is a crime. In any of these cases, Monnos may suspend or permanently cancel the access of the User in question to all the services and features of the Platform, without prior notification and without prejudice to other measures that are ensured by the legislation in force.
6.4. Monnos may, at its sole discretion, request additional documents and information to confirm or maintain access for any User. If Monnos decides to exercise this power in relation to any User, that User’s access may be suspended or definitively canceled if that User refuses to provide the information or to send the required documents or, if it is found, from the analysis of such information and documents, that the User has entered false or incomplete information.
6.6. Monnos reserves the right to unilaterally terminate the relationship with its Users, suspending access to the Platform, due to commercial disinterest, subject
to prior notification within a minimum of three business days and other measures necessary to prevent damage to the User.
Monnos will present Users with an integrated interface with several intermediaries that buy and sell cryptocurrencies or other digital assets based on blockchain technology (“Exchange Hub”). In addition to the approximation between Users who buy and sell crypto, it is still possible to take advantage of the Wallets, Sync Strategy and Crypto Saving Account features, defined, respectively, in items 7.1, 7.2 and 7.3.
7.1 Wallets. The Platform allows Users to create one or more portfolios or wallets, according to their strategies. The User can compose their portfolios with the cryptographs of their choice that are available for trading. Each of the wallets created by the User can contain an unlimited amount of cryptocurrencies, choosing a base currency for presentation of the consolidated balance.
7.2. Sync Strategy. Every wallet is born private (“private”), that is, visible only to its owner, and Users can modify it whenever they want the status of their wallets to be public (“public”).
7.2.1. When a wallet is born, it goes through category indexing, ranking and reputation algorithms, when this data is made public, these data are also published.
7.2.2. When selecting the public wallet mode, the User agrees that other Users can follow their strategies (“followers”) and defines an amount to be charged per follower. The follower accepts the fee the moment it starts to follow a strategy (“subscription”). Monnos gets 20% of the fee charged.
7.2.3. When choosing to follow a strategy, the User agrees and declares to be aware that all the movements of the strategy owner will be carried out automatically in his Wallet, in the selected proportion. In addition, it declares to be aware of the risks involved in any allocation of crypto assets, and assumes sole responsibility for any loss of the amounts invested.
7.2.4. The User, when choosing to subscribe, is aware that costs will be incurred in the transactions made by the owner of the portfolio and that these values will be divided proportionately between both, User and owner of the Strategy.
7.3. Crypto saving account. When choosing to use the platform, the option “Crypto saving account” will be automatically activated, thus, the User authorizes and declares to be aware of the following:
7.3.1. The User, as a lender and legitimate owner of the crypto assets available on the Monnos Platform, agrees to lend to Monnos, for an indefinite period (while
using the platform), the total assets he has, whenever Monnos realizes the possibility of using the “Crypto saving account” application.
7.3.2. During the loan period, Monnos, in case of gains, will gratify the User in a pre-defined percentage, on the Platform, weekly, without any guarantee of fixed or variable return, in the case of a random result contract.
7.3.3. The User can withdraw from the loan, withdrawing their values from the Platform, at any time.
7.3.4. In the absence of an express withdrawal of funds, if the User continues to make his crypto assets available on the Monnos Platform, the loan will be considered effective during the application of the ‘Crypto saving account’, and will produce all its normal effects.
7.3.5. Monnos undertakes to return to the User, whenever requested, the balance of virtual currencies present in the requesting User’s portfolio at the time of the order, plus compensation, if any, deducting the fees corresponding to the operations carried out.
7.3.6. The availability of the balances borrowed from Monnos will occur as follows: (i) after the express withdrawal manifest, Monnos delivers the borrowed crypto assets within 48 (forty-eight) hours; (ii) the additional amounts will be made available weekly, regardless of the redemption request, including residuals, if any, after the withdrawal manifestation.
8. Monnos Token
Monnos issues its own tokens within the Platform to its Users. The issuing of such tokens occurs in specific situations. The chances of issuing the Monnos Token, together with the incentive forecasts for using the Monnos Token within the Monnos Platform, are as follows:
8.1. Bonus Program / Use and Earn. The User participates in a reward system for use. The User can earn Monnos tokens with all the amount spent on the Platform. The amount of tokens received varies according to a dynamic mathematical formula, which has as one of its variables the amount spent on exchanges within the platform. The User does not earn Monnos tokens when payment is made with the Monnos token itself. This bonus will be available under strategic evaluation by Monnos.
8.2. Discounted Payment Made with Monnos Tokens. Users who pay for services offered by the Platform with Monnos tokens earn a discount on the payment for these services. These discounts will be defined by the Monnos team at any time;
8.2.1. Monnos Actions and Promotions. Monnos will launch, at any time, actions and promotions aimed at Users who accumulate Monnos tokens and that make use of certain functionalities that may be aligned with the company’s growth strategy.
In order to encourage the use of the Platform and the creation of a community around the product, Monnos will carry out a referral policy. The Monnos User who makes an indication will earn a dynamic percentage defined by Monnos according to its strategy and for the period that it determines. These percentages will apply to fees charged on trade movements and subscriptions made by the indicated Users.
10. Fees and Commissions
The download of the App and access to the Platform are free. Fees will be charged for the use of certain features within the Platform, the amounts of which are provided here: Click here to see Monnos conditions.
10.1. Updates. The entire Monnos pricing policy may be revalued, updated and adjusted at the sole discretion of the Monnos team. Policy changes and price adjustments and updates will be duly communicated on the Platform. If you do not agree with the changes in the pricing policy or the adjustments and updates, you should stop using the Monnos Platform.
11. Risks associated with using the Platform
The User, by agreeing to these Terms, declares to be aware of the risks involving the option to apply his cryptography in the Sync Strategy function, in operations involving the Crypto saving account and other options available on the Platform, assuming responsibility for any losses arising from such options made, in accordance with the provisions of item 12.
12. Limitation of Liability and User Obligations
Monnos indicates that the activities carried out on the Platform are considered to be extremely high-risk activities, implying the acceptance, by the User, of the possibility of financial losses due to the manipulation of cryptocurrencies and other digital assets based on blockchain technology through the use of the Platform. When using the Platform the User is aware of the risks that the use of cryptocurrencies implies. Monnos is not responsible for any losses caused as a result of speculative activities performed by the User in relation to the cryptocurrency market, even if such activities are carried out through or through the Platform. Monnos is also not responsible for any losses in the total amount of cryptocurrencies of the User arising from an act of third party, self-putting at risk, in case of force majeure, or for the risks inherent in the application of cryptocurrencies in the Sync Strategy option or any other functionality speculative market and / or due to the options that the User selects on the Platform. The User declares that the risks involving the applications are known to him and are outside the scope of Monnos’ activities. The User can question difficulties of technical and technological origin via the Customer Service System (SAC) or by contacting them directly via email provided on the Platforms. IN NO EVENT SHALL MONNOS BE LIABLE FOR ANY LOSSES, DAMAGES, LOSSES OR LOST PROFITS THAT THE USER MAY RESULT DUE TO NEGOTIATIONS CARRIED OUT OR NOT CARRIED OUT THROUGH THE PLATFORM.
12.1. Monnos is not responsible for any errors made by the User when registering his bank details or wallet address.
12.2. Monnos is committed to making the best efforts to connect to Exchange platforms with a high degree of security, transparency and trust. However, Monnos is not responsible for any losses resulting from failures, errors or any other types of acts or facts occurred by or from exchanges linked to the Platform, whether related to functionality as well as civil and / or criminal responsibilities.
12.3. The Platform’s services are subject to interruptions, delays and problems inherent in the use of the Internet. Monnos will not be responsible for any of these interruptions, delays or problems, or for any defects or limitations of the equipment or the navigation program used by Users, or for any defects or limitations of the services providing access or access infrastructure to the Internet. Internet hired by Users. Monnos will also not be responsible for any virus that could attack the User’s equipment as a result of accessing, using or browsing the Internet or as a result of the transfer of data, files, images, text or audio.
12.4. Monnos does not act and cannot act as a consultant, including in financial, legal, investment, insurance and / or tax matters. Any information provided by Monnos or obtained through the Platform’s functionalities is considered general information and does not replace consultation with the expert in the respective area. The User is solely responsible for the options he selects.
12.5. Monnos will not be responsible for delays, failures in performance or interruptions in its services that result directly or indirectly from any causes or conditions that are beyond its reasonable control, including, but not limited to, any delay or failure due to occurrence act of God or force majeure, acts of civil or military authorities, acts of terrorism, civil unrest, war, strike or other labor dispute, fire, interruption of telecommunications or Internet services or network provider services, equipment failure and / or software, other catastrophe, or any other event beyond Monnos’ reasonable control.
12.6. The User agrees and declares that he will not use the Monnos Platform to carry out any type of illegal activity or to take any action that adversely affects the performance of the Platform. The User may not engage in any of the following activities through the Platform, nor may he assist third parties in any of the following activities: (1) attempting to gain unauthorized access to the Monnos Platform or another User’s account, (2) making any attempt diversion or circumvent any security features, (3) violate any law, statute, ordinance or regulation, (4) reproduce, duplicate, copy, sell or resell the Monnos Services for any purpose, except as authorized in these Terms, (5) participate in any activity considered abusive, which interferes or interrupts the functionality of the Platform. If the User is blocked by Monnos and cannot access the Platform (including by blocking his IP address), the User agrees not to implement any measures to circumvent such block (for example, by masking his IP address or using an IP address proxy). THE USE OF THE MONNOS PLATFORM IN CONNECTION WITH ANY TRANSACTION INVOLVING ILLEGAL PRODUCTS OR SERVICES IS PROHIBITED.
12.7. Password reset process
Option 1 – LOGGED USER and AWARE OF HIS OWN DATA:
– When the user is logged in, and remembers perfectly all of his current authentication factors such as SMS, EMAIL or TOTP (Google Auth, Authy and others), he can change his password inside the monnos application.
Option 2 – USER NOT LOGGED and FORGOT PASSWORD:
– In cases of forgetting the “PASSWORD” authentication factor, the “forgot password” process can be triggered outside the context of an authenticated user, it will be conducted to introduce its current security factors, in which it can be SMS, EMAIL, TOTP (Google Auth, Authy and others), with several possible combinations, depending on the security level of your account, as this is customizable.
Option 3 – USER LOST PHONE and requests access:
– In the case of a lost or stolen phone, or the impossibility of receiving an SMS factor, the user will be able to access the support and request a temporary removal analysis of the SMS factor, thus automatically activating the EMAIL factor to be able to authenticate in the MONNOS application. , and thus being able to change the password when checking account level 2 (KYC 2). The same user will not be able to change the password outside the authenticated environment.
** this option is only accessible through support and having the “KYC level 2”, otherwise you will not have access, and you may even lose access to the remaining resource in this account.
12.8. Monnos reserves the right to restrict the use of the Platform or to temporarily or permanently suspend the Users account, should any violation of this section occur, without prejudice to other applicable legal measures.
13. Repayment and reversal
Once the transaction has started, speaking of intermediation in the purchase and sale of crypto, as well as in the case of any other functionality available on the Platform, it is not possible to reverse the transaction. Likewise, payments and / or transfers related to such transactions are not redeemable. Therefore, it is not possible to reverse any transaction already started within the Platform, and there is no right of redemption against Monnos.
14. Intellectual Property Rights
Users acknowledge and agree that Monnos is the sole and exclusive holder of all copyright and intellectual property related to the Platform, including the domain name, programming, files, databases, content, design, features and other features, and that such rights are protected by law. The Monnos trade name, the Monnos brand and the products and services associated with that brand are the exclusive property of Monnos and its unauthorized use is subject to the consequences provided by law.
14.2. Users are prohibited from modifying or attempting to modify any functionality of the Platform, producing any derivations of the products and services offered by the Platform, or even accessing any part of the Platform in order to create a competing product or service, or any product or service that contains ideas, characteristics or functions similar to those of the Platform.
14.3. The use of any device, software or other resource that may interfere with the activities and operations of the Platform or that has the objective of improper access to the information or databases of the Platform is also not allowed.
14.5. The Platform may display links to other Internet sites, which does not mean that these sites are owned or operated by Monnos.
14.5.1. Monnos has no control over the content of other sites whose access is facilitated by links inserted in the Monnos Platform, and, therefore, will not be responsible for the content, practices and services offered on these other sites.
15. Final provisions
15.1. If, for any reason, a court of competent jurisdiction finds any provision of these Terms to be invalid or unenforceable, that provision will apply to the maximum permissible extent and the other provisions of these Terms will remain in full force and effect.
15.3. Monnos’ failure to exercise or enforce any right or provision of these Terms will not constitute a waiver of that right or provision.
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1. THE COMPLIANCE PROGRAM
Monnos has an effective Money Laundering and Illicit and Terrorist Financing Prevention Policy (PLDFIT). Monnos’s activities are guided by the content of its PLDFIT Policy, which is always evolving and in line with the characteristics of its market, as well as by legal, normative and ethical imperatives applicable to its activity. In this way, Monnos assures its customers and regulators and other market members the smoothness of its operations.
The PLDFIT Policy is structured to combat the commission of illicit acts, divided into different components that converge for this purpose. Like other entities in the financial system, Monnos values the identification of its clients – which must be kept up to date – in line with recommendations from the Financial Action Task Force (FATF) and Bank for International Settlement (BIS). Indeed, people identified as politically exposed will be treated differently by the Monnos team.
Another pillar of the PLDFIT Policy is the registration and identification of transactions. In a market where transactions take place at significant amounts and speed, the potential for illegal practices cannot be ignored. In this way, Monnos keeps an eye on the financial movements carried out under its supervision – be they between crypto, be it between crypto and fiduciary currencies – always willing to collaborate with competent authorities in case of suspected violation of the law. It is also emphasized that Monnos does not receive cash, thus ensuring transparency and documentation of transactions.
Of equal importance is the preparation of the team. In addition to those directly involved with the compliance industry, everyone must be aware of evidence of wrongdoing and willing to identify and report such behavior to the appropriate industry. The compliance culture is reinforced by everyone on the Monnos team; from its CEO to the newest employee, everyone understands the relevance of the PLDFIT Policy.
Also in this field, the transactions to be carried out at Monnos will respect limits corresponding to the degree of customer documentation. That is: to move higher amounts, Monnos customers must undergo more scrutiny and may have their limit expansion request denied. New documents can be ordered at any time, and collaboration with demands is essential.
These grounds set forth in no way end Monnos’ PLDFIT Policy; Only here is Monnos’ degree of commitment to compliance with the law and appreciation of good faith and transparency.
2. RISK OF THE CRYPTACTIVE MARKET
Cryptoactive are not fiat money. This means that they are not regulated by any central bank or other government entity and, depending on their characteristics, may not have any intrinsic value. The risk of financial loss is a factor to be considered during any operation.
3. RULES APPLICABLE
The legal rules governing the crypto market are still scarce. However, Monnos remains in harmony with legal regulations regulating the traditional financial market. Seeking to mitigate the risks of wrongdoing – financial or otherwise – Monnos has developed its PLDFIT program by following recommendations and laws from different agencies and jurisdictions.
It is noteworthy that Monnos is not a traditional financial institution, which is why, in principle, the rules for companies in this segment are not fully applicable to Monnos. However, understanding that fighting illicit acts is a common goal of all, Monnos is constantly seeking and implementing the dictates that best serve this purpose.
4. UNAIDS COUNTRIES
Because of the risk inherent in its operations with these States, Monnos will not serve resident or headquartered individuals or entities in the following jurisdictions: Afghanistan, Saudi Arabia, Bahamas, Botswana, Cambodia, North Korea, Ethiopia, Ghana, Guam , Guinea-Bissau, Yemen, US Virgin Islands, Iran, Iraq, Lebanon, Libya, Mali, Nigeria, Panama, Pakistan, Puerto Rico, Central African Republic, Democratic Republic of the Congo, Samoa, American Samoa, Serbia, Syria, Somalia , Sri Lanka, Sudan, South Sudan, Trinidad and Tobago, and Tunisia.
In turn, people with connections to Balkan states – Albania, Bosnia and Herzegovina, Bulgaria, Greece, Northern Macedonia, Montenegro, Serbia, Kosovo, Croatia, Romania, and Slovenia -, Belarus, Burundi, Cuba, Nicaragua, Ukraine, Venezuela and Zimbabwe should undergo a differentiated registration procedure.
Finally, regardless of the foregoing jurisdictions, Monnos operations are not available to residents of the United States or China.
5. COOPERATION WITH PUBLIC AUTHORITIES
Monnos values cooperation with public agencies in the fight against corruption, money laundering and terrorist financing. Any authority may contact Monnos to comply with legal, judicial or regulatory requirements through the following channel: email@example.com or firstname.lastname@example.org.
Anyone who becomes aware of unlawful practices that in any way involve Monnos should immediately report to Monnos via internal communication channels, in particular, the following email address: email@example.com.
Anonymous reports are accepted, provided they are corroborated with evidence or evidence that allows the internal team to elucidate the facts.
7. FINAL STATEMENTS
The Money Laundering and Illicit and Terrorist Financing Prevention Policy, in its entirety, is only available to those who have a close relationship with Monnos, due to the need for confidentiality of the compliance measures adopted.
Refusal to provide any documents or information requested by Monnos may lead to termination of the relationship without further explanation.
In the case of the same document with translations in different languages, the Portuguese version will prevail.
Updated on September 9, 2019